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Comments Submitted to OMB in Support of the Social Cost of Carbon

February 26, 2014

Policy Integrity submitted comments to the Office of Management and Budget (OMB) voicing our support for the Administration’s continued use of the social cost of carbon (SCC) as it provides an important, if conservative, estimate of the costs of climate change and the benefits of reducing carbon pollution.

The SCC is an estimate of the damage caused by each ton of carbon emissions. It is used in the cost-benefit analyses of regulations that seek greenhouse gas emissions reductions. The estimate is a vital part of creating effective policies that protect our environment and people’s health and well-being. It is the best available tool that helps inform the most accurate cost-benefit analyses for good public policy decisionmaking.

Our comments, submitted jointly with the Environmental Defense Fund, Natural Resources Defense Council, and the Union of Concerned Scientists, specifically address the Interagency Working Group’s Technical Support Document under Executive Order 12,866.

While we urge the OMB to direct the Administration and all relevant agencies to continue using the SCC, we find that the current version is biased downward. We encourage regular updates that reflect the latest science and economics.

Policy Integrity has long supported using the SCC while encouraging future work on improving the estimate. In October 2013, our group, along with those listed above, submitted comments opposing a petition for correction on the SCC. The petition for correction seeks to stop government agencies from using the current estimates. We explain why the petitioners’ arguments are wrong and why they should be dismissed. We also argue that the SCC is in fact likely to be significantly underestimated, rather than inflated, as the petitioners claim. We have noted our concern about the underestimation in comments to the Department of Energy in November 2013, as well as in comments submitted in October.